RS-14-291, Proposed Alternative Testing Requirements for ASME Class 1, 2, and 3 Valves in an IST Cold Shutdown Justification or Refuel Justification

Proposed Alternative Testing Requirements for ASME Class 1, 2, and 3 Valves in an IST Cold Shutdown Justification or Refuel Justification

ML14335A541
Person / Time
Site:	Clinton
Issue date:	12/01/2014
From:	Simpson P Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RS-14-291
Download: ML14335A541 (4)

Text

4300 Winfie!d Road 411111111111W Warrenwile. IL 60555 4111M1Pmr 0/11/10111fr on Generation 630 657 2000 Office RS-14-291 10 CFR 50.55a December 1, 2014 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-001 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461

Subject:

Proposed Alternative Testing Requirements for ASME Class 1, 2, and 3 Valves in an 1ST Cold Shutdown Justification or Refuel Justification Pursuant to 10 CFR 50.55a, "Codes and Standards," paragraph (a)(3)(i), Exelon Generation Company, LLC (EGC), hereby requests NRC approval of a request for a proposed alternative to the requirements of the American Society of Mechanical Engineers (ASME), "Code for Operation and Maintenance of Nuclear Power Plants," (ASME OM Code), Subsections ISTC-3521(e), ISTC-3521(h), ISTC-3522(c) and ISTC-3522(f) for Clinton Power Station (CPS).

These OM Code subsections require that Cold Shutdown Justification (CSJ) and Refuel Shutdown Justification (RFJ) valves be tested each refueling outage. CPS will be transitioning to a 12 month fuel cycle beginning in the Spring of 2015; performing a refueling outage every 12 months. CPS intends to alternately schedule one short outage that will focus primarily on refueling activities with minimal maintenance activities (i.e., "refueling only outages") and one more traditional refueling outage consisting of both refueling activities and maintenance activities (i.e., "refueling/maintenance outages"). This request proposes to allow testing of these valves on the current 24 month testing frequency. This will allow CPS to maintain a minimal amount of testing during the "refueling only outage" and still maintain the same level of quality and safety by continuing the two year frequency that these valves have historically been tested at during the "refueling/maintenance outages." The details of this request are provided in the attachment to this letter.

EGC requests approval of this relief request by December 31, 2015 to support scheduling for future refueling outages following the CPS transition to a 12 month fuel cycle.

There are no regulatory commitments contained in this letter.

December 1,2014 U. S. Nuclear Regulatory Commission Page 2 Should you have any questions concerning this letter, please contact Mr. Timothy Byam at (630) 657-2818.

Respectfully, R

Patrick R. Simpson Manager Licensing Exelon Generation Company, LLC

Attachment:

10 CFR 50.55a Request Number 2203 Proposed Alternative In Accordance with 10 CFR 50.55a(a)(3)(i) cc: NRC Regional Administrator, Region III NRC Senior Resident Inspector Clinton Power Station Illinois Emergency Management Agency Division of Nuclear Safety

ATTACHMENT Proposed Alternative In Accordance with 10 CFR 50.55a(a)(3)(i)

Page 1 of 2 10 CFR 50.55a Request Number 2203 Proposed Alternative In Accordance with 10 CFR 50.55a(a)(3)(i)

Alternative Provides Acceptable Level of Quality and Safety

1. ASME Code Component(s) Affected All ASME Class 1, 2, and 3 valves included in a Clinton Power Station (CPS) In-Service Testing (1ST) Cold shutdown (CSJ) or Refuel Justification (RFJ).

2. Applicable Code Edition and Addenda

American Society of Mechanical Engineers (ASME), "Code for Operation and Maintenance of Nuclear Power Plants," 2004 Edition (ASME OM Code-2004).

3. Applicable Code Requirement

ISTC-3521 Category A and Category B Valves ISTC-3521(e) if exercising is not practicable during operation at power or cold shutdowns; it may be limited to fullstroke during refueling outages.

ISTC-3521(h) all valve testing required to be performed during a refueling outage shall be completed before returning the plant to operation at power.

ISTC-3522 Category C Check Valves ISTC-3522(c) If exercising is not practicable during operation at power and cold shutdowns; it shall be performed during refueling outages.

ISTC-3522(f) All valve testing required to be performed during a refueling outage shall be completed before returning the plant to operation at power.

4. Reason for Request

In accordance with 10 CFR 50.55a(a)(3)(i), relief is requested from the requirements of the OM Code, Subsection ISTC-3521(e), ISTC-3521(h), ISTC-3522(c) and ISTC-3522(f). The proposed alternative would provide an acceptable level of quality and safety.

These sections require CSJ and RFJ valves to be tested each refueling outage. CPS is currently on a 24 fuel month cycle, thus, CSJ and RFJ valves are currently tested every 24 months. For financial reasons, CPS will be transitioning to a 12 month fuel cycle beginning in the Spring of 2015; performing a refueling outage every 12 months. CPS intends to alternately schedule one short outage that will focus primarily on refueling activities with minimal

ATTACHMENT Proposed Alternative In Accordance with 10 CFR 50.55a(a)(3)(i)

Page 2 of 2 maintenance activities (i.e., "refueling only outages") and one more traditional refueling outage consisting of both refueling activities and maintenance activities (i.e., "refueling/maintenance outages"). Based on the above referenced code requirements, CPS will be required to test all CSJ and RFJ valves every year. This in effect cuts the testing frequency of these valves in half (i.e., one year vs two years). This change in outage scheduling and its OM Code implications do not provide a compensating increase in level of quality or safety.

This relief request is being pursued to maintain the current (i.e., two year) testing frequency for the CPS CSJ and RFJ valves. This will allow CPS to maintain a minimal amount of testing during the "refueling only outage" and still maintain the same level of quality and safety by continuing the two year frequency that these valves have historically been tested at during the "refueling/maintenance outages."

5. Proposed Alternative and Basis for Use CPS proposes to continue testing CSJ and RFJ valves every two years with the CSJ valves being tested during all cold shutdowns lasting longer than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> and continuing until the plant is ready to return to operation at power per ISTC-3521(g) and ISTC-3522(e). Based on the current outage plans, CPS proposes treating the "refueling only outage" as a cold shutdown in accordance with OM Code requirements and not a refueling outage. This will maintain the current time between tests at every two years for the CSJ and RFJ valves.

By maintaining the current testing frequency, CPS maintains the current acceptable level of quality and safety with regards to the CPS RFJ valves. This change in outage schedules will also increase the level of quality and safety for the CPS CSJ valves due to the planned outage in between the "refueling/maintenance outages" that will provide time to perform some of the CSJ valve testing. This statement is supported by the years of testing these valves at a 24 month interval.

In summary, CPS is proposing to test all of its CSJ and RFJ valves every two years during the "refueling/maintenance outages" and continue testing the CSJ valves as time allows during the "refueling only outage" to satisfy the requirements of ISTC-3521(g) and ISTC-3522(e). This will maintain the current time between tests for the CSJ and RFJ valves at a maximum of two years.

6. Duration of Proposed Alternative The proposed alternative identified in this relief request shall be utilized during the Third 10-Year 1ST Interval.